You must read to fully understand all data protection measures we have adopted. By submitting your personal data to us by using our website and/or our services, we understand that you have accepted the terms of this Policy.
What personal data might we collect?
We collect different types of personal data for different reasons – this may include:
Contact information: Information such as your name, job title, postal address, home address where you provide this to us, business address, telephone number, mobile number, fax number and email address.
Business details: Business information which we necessarily process for the projects we are involved in or otherwise provided by you voluntarily.
Preferences: Information about your preferences, where it is relevant to the services we provide.
When do we collect your personal data?
We may collect personal data about you in various cases, such as for example:
• When you or your organisation make an enquiry through our website, in person, over email or over the telephone;
• When you attend events organized by us, or sign up to receive communications from us;or
• When you or your organisation provide services to us, or otherwise offer to do so.
In some circumstances, we may collect personal data about you from third parties – for example, we may collect personal data from your organisation, other organisations with whom you have dealings including government agencies, an information or service provider or from a publicly available record.
How will we use your personal data?
We will use your personal data for the following purposes (“Permitted Purposes”):
• For us to act as an information sharing platform on Hong Kong divorce procedure and related matters;
For compliance with our legal obligations (such as record keeping obligations), which may include automated checks of your contact data or other information you provide about your identity and contacting you for compliance purposes;
• To analyse and improve our services and communications to you;
• To protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and to detect security threats, fraud or other criminal or malicious activities;
• For insurance purposes;
• To monitor and assess compliance with our policies and standards;
• To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory, law enforcement and tax reporting bodies;
• On instruction or request from your organisation;
• To communicate with you through the channels you have approved to keep you up to date on the latest legal developments, announcements, and information about any events and or projects we may organize; and
• For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.
Where you have expressly given us your consent, we may process your personal data also for the following purposes:
• For customer surveys, marketing campaigns, market analysis, contests or other promotional activities or events; or
• To collect information about your preferences to create a user profile to personalise and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).
With regard to newsletters, legal updates and other general communications, we will – where legally required – only provide you with such information if you have opted in. You have the opportunity to opt out of receiving such communications at any time. We will not use your personal data for taking any automated decisions affecting you or creating profiles other than described above.
Depending on for which of the above Permitted Purposes we use your personal data, we may process your personal data on one or more of the following legal grounds:
• To comply with our legal obligations; or
• Because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms.
We may also process your data based on your consent where you have expressly given that to us.
How will we share your personal data?
We may share your personal data in the following circumstances:
• We may share your personal data with any third party to whom we assign or novate any of our rights or obligations;
• We may share your personal data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
• We may also instruct service providers domestically or abroad to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. We will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers; and
• We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.
We will otherwise only disclose your personal data when you direct us or give us permission to do so, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
Can you refuse to share your personal data with us?
In general, we receive your personal data where you provide this on a voluntary basis, and there will typically be no detrimental effect for you if you wish not to provide this or otherwise withhold your consent for it to be processed. However, there are certain cases where we will unfortunately be unable to act without receiving such data, for example where we need such data to provide you with our online services or communications.
Where it is not possible for us to provide you with what you request without the relevant personal data, we will let you know accordingly.
How do we keep your personal data safe?
We take appropriate technical and organisational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data. We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files.
Personal data we receive from you about other people
Where you provide us with the personal data of other people, such as your employees, directors of your companies, or other persons you may have dealings with, you must ensure that you are entitled to disclose that personal data to us and furthermore that, without being required to take further steps, we can collect, use and disclose that data in the manner described in this Policy. More specifically, you must ensure that the individual whose personal data you are sharing with us is aware of the matters discussed in this Policy, as these are relevant to that individual, including our identity, how to get in touch with us, the purposes for which we collect data, our disclosure practices, and the rights of the individual in relation to our holding of the data.
Transfers of personal data abroad
Due to the nature of our operation, we may transfer your personal data abroad if required to do so for the Permitted Purposes. In certain cases, this may include transferring data to countries which do not offer the same level of protection as the laws of your country (such as for example the data protection legislation of the EU/EEA).
When making such transfers, we will ensure that they are subject to appropriate safeguards in accordance with the General Data Protection Regulation (Regulation 2016/679) or other relevant data protection legislation. This may include entering into the EU Commission’s Standard Contractual Clauses. Please get in touch with our Data Protection Officer at [email protected] if you wish to obtain further information on the appropriate safeguards which we are adhering to.
How long do we keep your personal data?
We delete your personal data once it is no longer reasonably necessary for us to keep it for the Permitted Purposes, or, where we have relied on your consent to keep your personal data, once you withdraw your consent for us to do so, and we are not otherwise legally permitted or required to keep the data.
In determining the appropriate retention period for personal data we consider such factors as the nature of the information, the purposes for which the data is retained, appropriate security measures, relevant technical constraints and applicable legal requirements. Please contact us if you want further information about our record retention policy.
What rights do you have?
Subject to certain conditions under applicable legislation, you have the right to:
• request a copy of the personal data which we hold about you;
• have any inaccurate data we hold about you corrected;
• object or restrict our use of your personal data;
• submit a complaint if you have concerns about the way in which we are handling your data.
To do any of the above, please contact us at [email protected]. To enable us to process your request, we may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification – this is to ensure that we appropriately protect the personal data we hold from unauthorised access requests and comply with our security obligations.
We may charge you a reasonable administrative fee for any unreasonable or excessive requests we may receive, and for any additional copies of the data you may request.
In relation to complaints, we will promptly respond to your requests and complaints. In the event that you are unhappy with our response, you may submit a complaint to the relevant privacy regulator. We can provide you with the details of the relevant regulator upon request.
Correcting and updating your personal data
Where any personal data you have provided us with has changed, or where you believe the personal data we hold is inaccurate, please let us know at [email protected]. In addition, please note that if you hold an office in an organisation, you and/or the organisation may have a contractual or legal obligation to notify us of any change within a prescribed time period. We cannot be responsible for any loss that may arise due to us having any inaccurate, incomplete, inauthentic or otherwise deficient personal data which you or an organisation have provided to us..
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Get in touch
We would be happy to hear your views about our website and this Policy – please let us know any questions, comments or clarifications you may have at [email protected]